Fred Allebach
6/5/24
Public comment
Land Use and Socioeconomics chapter of General Plan (GP) Existing Conditions Report (ECR)
My advice, there’s one land use choice, upzone all residential areas to an equal mix of high, medium and mixed use, make low density only 25% of total residential zoning. Single family zoning (SFZ) and single-family homes (SFHs) are a significant majority of city land use. This is synonymous with exclusionary zoning and needs to change a LOT. SFHs, stand alone and attached are 75% of all city residential units. The city is currently 70+% SFZ when the rural residential zoning category is included. How can land use diversity be achieved when preserving suburban segregated zoning is a top goal? All lower income people must live in commercial areas? The Land Use map needs serious changes.
The City is in a pickle in that preserving an unjust status quo is a top priority.
The GP has two core competing priorities, being inclusive vs. being exclusive
There is no clear policy path to finesse this tension; this tension needs to be put on the table and addressed by the Council. The GP needs plans to reconcile these conflicting goals. Having fundamentally conflicting goals is inconsistent. The GP can’t be “consistent” with such a wide-open gulf of priorities. Diversity and equity are claimed as city values but protecting exclusivity is the dominant theme. Something has to give here.
Low density character and neighborhood compatibility are code for maintaining exclusivity and segregation. Part-ways the inclusive/ exclusive dynamic is one of a conflict of interests between 40% renters and 60% property owners. In the US, the unlanded are equal citizens and stakeholders and suburban cities should not be syndicates to protect owners over renters.
Long term RHNA deficit
The facts not on the table for city RHNA performance from 2000 – 2020. In this time frame, Very Low, Low and Moderate units were underproduced by 263 and Above Moderate were overproduced by 296. Why is there such resistance from the city to cite this? The city has a housing equity deficit running and won’t admit it.
UGB
The UGB’s four poison pill clauses are a gov’t constraint on housing. The UGB is not sufficiently flexible. What we have in Sonoma is a Green Checkmate, a choice that maintains segregation; green values and neighborhood character values eclipse equity values.
The UGB “encourage(s) sustainable growth.” With sustainable used as such a weasel word, who can say what sustainable growth is? The GP needs to include economic and social factors here.
Data
Data used presents a no-equity, anodyne view. Segregation not seen, ignored, therefore there is none, justified away. DACs are defined by DWR differently than by Cal EnviroScreen, by choosing certain views, the city is methodologically blind, does not see real patterns. If the ECR set the baseline of how things are, the assumption seems to be to make it so general as to elide many serious issues that need attention.
ACS data can suss out a lot of demographic info as I did in my own ACS studies. The Housing Element (HE) low-balled local geographies with a Tract-level view, now a foolish consistency with this HE view and too general a GP view foils seeing the actual in existing conditions.
The GP too-general view is inaccurate and misses critical demographic facts. The GP is not catching significant wealth disparities, not seeing it.
GP monthly housing costs seem unrealistically low. If prices were as GP says there would not be a housing crisis. I cannot find anything for those prices.
There are DACs in contiguous unincorporated areas in the GP analysis period that cuts off in 2023. No excuse to not see the actual.
Land Use Map: Please increase diversity of land uses
Sonoma has 65% single family zoning (SFZ), 70% if the rural residential category is included. How to get to demographic diversity when protecting exclusionary zoning is a top city goal?
SFZ and SFH residential areas qualify as underutilized space; if this space is not pursued for higher density infill, the city is not serious about land use changes to amplify needed race and class diversity. Martinez v Clovis case law shows that SFZ is indeed underutilized space and is linked to segregation and lack of AFFH
Housing Element and current zoning land use now puts all equity chips and onus on the Hwy 12 commercial strip. 88% of 6th cycle RHNA for Low and Very Low-income units is put on three sites on Hwy 12, two of these on West Napa have feasibility issues. These two W. Napa sites are also in the poorest part of town while the wealthier, SFZ east side will have only one Low income unit for the whole 6th cycle.
The UGB deal in a two square mile city is for the city to take denser infill and to support more inclusion and diversity, so much single-family housing (SFH) and SFZ has to change if land use equity values are to succeed. All equity can’t be foisted on a commercial strip on the poorest side of town. This just preserves a segregated suburban stasis.
AFFH is methodologically elided in HE and GP by too general a focus
The city west side is significantly poorer with lower scores overall. The GP and HE are not seeing the actual with tract and city level analysis. Why be consistent with a wrong view?
Suggestions for land use changes
Upzone a lot
Sonoma’s 70% SFZ and SFH segregates by class and race; the poor, the bottom of the hourglass, get Mixed Use and Commercial zoning, this with the stilted lower income RHNA site inventory seems to add up to AFFH violations. All the poor in high density Commercial is a feudal living arrangement. The workers can get no neighborhood character?
Land use map
Fig 1.1-2 fails to note Sonoma Valley hop scotch development of sanitation plant, Temelec, and 8th E industrial area. The Urban service area of developable land needs to be noted
With the chart showing dates of earlier residential development patterns, if cross-town variances can be shown for building ages, why not for other indicators like race, MHI, why can’t we see local texture socially like is presented here for buildings? Clearly more social detail can be noted, the GP ECR needs to do this.
Sonoma Residential zoning is for “middle income households.” What area median income (AMI)/ and median household income (MHI) is that? The city needs consistency with terms like missing middle, middle income. With an hourglass economy there is no more middle class.
Housing Opportunity Sites
One more is now lost to the First Street East (FSE) project, almost all these HO sites go market rate. It’s a farce, Sonoma has not done sufficient work to stem this trend of loss of HO sites. This HO category should be tossed or else made to have teeth.
Get rid of the 850 sf exemption in the inclusionary ordinance ASAP, make the inclusionary ordinance a stand-alone law that supports lower income units and not with any loopholes.
Upshot is that Lower-income cohorts don’t get to enjoy any neighborhood character.
Hillside zoning, it’s ironic that all of SV has lots of hillside housing, a lot in the hills right behind city hall. SV views are already ruined by wealthy mansions.
Open space zoning, use the city-owned St Francis preserve area fir a big 100% AH project ASAP, get moving, give the land to SAHA.
Housing policy make a stronger push on AFFH
HE goals H-1,2,3,4,5 are countermanded by all the SFZ and character protection. This stems from the core GP city conflicting priorities of inclusion vs exclusion. Consistency and compatibility with small town/ neighborhood character is code for maintaining segregation, a modern redlining Trojan Horse. HE and GP should not wishy wash segregation.
If Sonoma is not a syndicate to protect SFZ and harvest elite tourism revenue to fund the city, then a much stronger push on AFFH is needed in the GP.
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